PARTNER PRIVACY POLICY

1. Our Company Details

2. We Respect Your Privacy

3. Collecting Your Information

• Identifying Information: Information you give us about yourself to create or update your personal account on our Website (“Partner Account”). This may include your name, email address and password;
• Optional information: Additional information you choose to populate your Partner Account with, such as your phone number;
• Communication information: Information we may collect about you from e-mails or physical letters you send us, or through any other communication, including mobile phone numbers to contact you on;
• Usage information: Information we may collect about your use of our Service, such as the date of creation (or validation, if created by another user) of your Partner Account, account use timings and general account use;
• Technical information: Information we may collect about your use of a mobile or other device to access our Website. This may include device-specific information such as device type, operating system, browser and connection information, IP address, performance and other characteristics data, and other types of technical information;
• Compliance information: We may obtain information that includes personal information about you from various sources (including those offline and online, such as social media, LinkedIn, your CV and so on); and
• Special information: Please note that we do not collect or use any special classes of data (which includes data such as health information and political opinions).

4. Using Your Information

• Service offering: To provide the Service to you detailed in our Partner Terms & Conditions, including the need for our internal record keeping and verifying the identity of specific person(/s) associated with Partner Accounts;
• Service maintenance and improvement: The ongoing running and improvement of our Service for you and other Partners, which requires us to understand how you use the Website. When you are logged into the Partner Account, we use Google Tag Manager to deploy analytics tools such as Microsoft Clarity. These tools help us operate, troubleshoot, and improve your Partner Account, ensure its security, and understand how business users interact with our features. Session recordings and analytics in this context are not used for advertising or cross-site tracking. We mask personal information displayed on-screen (e.g. names, email addresses, transaction details) so it is not visible in recordings. The lawful basis for this processing is performance of a contract (to provide the Partner service you signed up for) and legitimate interests (to operate and improve the service); Our ongoing business obligations: Including operations such as analysing data (for example to prevent fraud and other abuses), ensuring we have the required information for security, reporting and other requirements, and ensuring we comply with relevant regulations and the law;
• Business communication: This includes communicating with you in reply to communications you have initially sent to us, sending reminders, important notices, warnings, soliciting your opinions on the current functionality or potential aspects of our Service, communicating about updates or changes to our Service, matters specifically relating to your Partner Accounts or business itself, and other matters related to those detailed in the Partner Terms & Conditions, this Partner Privacy Policy, and other important documents referred to; and
• Compliance: This includes information we have gained in order to check your inputted user credentials, that you are a member of the Partner business your account relates to, and for other compliance procedures we may deem necessary. Unless this is public information, we will ask for your explicit consent first. 

5. Legal Basis

• Consent: You have given us clear content, which can be withdrawn by emailing us at any time, to process your personal data for a specific purpose;
• Contract: The processing by us is required for a contract we have with you, or because we have been asked by you to take specific steps before entering into a contract;
• Legal obligation: The processing is required by law;
• Vital interests: We need to process the data to protect someone’s life;
• Public task: The processing is necessary in relation to if we perform a task in the public interest or for our official functions, and the task or function has a clear basis in law; and
• Legitimate interests: The processing is necessary for our or a third parties’ legitimate interests unless a good reason to protect your data overrides those legitimate interests. These legitimate interests include: (a) monitoring the use of our intellectual property; (b) complying with our internal procedures and policies; (c) enabling us to carry out our Service in respect to you both effectively and efficiently; and (d) ensuring our Website components, and other related systems and services, are secure.

6. Disclosure of Your Information

• Our Partner Terms & Conditions, provision of our Service and business operations, or other agreements between us may allow and/or require it (including collecting any payments that may be owed by you to us);
• Protection of our own rights, or those of other parties related to us, may require it;
• Legal obligations, regulatory or government requests may also ask or require us to share your information in certain circumstances (such as to investigate, prevent and protect against fraud and other illegal and criminal activity);
• You may allow us to give your personal contact information to a customer of yours who is a User and has contacted Steppr with the intent of communicating with you (we will ask you first unless you have expressly communicated previously that we may do this, or we may be legally obliged to pass your details on to the customer before asking you);
• Technology and IT service providers for process automations (such as MailGun for transactional emails), technical support, search engine providers and analytics services (such as Firebase Google analytics – which makes use of cookies, IDs and other technologies to collect and store user personal data, which you can read more about here: policies.google.com/technologies/partner-sites) that may help us improve and optimise the Platform; 
• If we are acquired or purchased by, merged with, sold to, or enter into a partnership or joint venture with another business entity (or are involved in negotiations for any of these cases), or create a subsidiary of Steppr, then your information may be correspondingly transferred or disclosed to that business entity, its partners, owners or advisors;
• Our auditing, compliance and corporate governance processes and procedures that are legally necessary may require it; and
• Your personal information may be disclosed to Partner Accounts that are connected to (or even created) your own, and vice versa, for the purposes of user management.

7. Where Do We Store and Process Personal Data?

8. Information Security

• Keep the password for your Partner Account for our Website safe;
• Do not use the same password for our Website as you use for other services;
• Do not remain signed in to our Website when you are not using it;
• Do not allow external access to your mobile device used for Two Factor Authentication;
• Do not allow any other parties to use your Partner Account; and
• If you have the required privileges and responsibilities for your Partner Account, you should remove any other affiliated Partner Accounts (managed in the “users” tab) which are no longer required.

9. Information Retention

10. Your Rights in Relation to Personal Data

• The right to be informed: You have the right to be provided with concise, transparent, intelligible and easily accessible information about our collection and use of your personal data, explained in clear and plain language. This is the intention of this Partner Privacy Policy, as well as your ability to contact us at team@steppr.com if you have any concerns;
• The right of access: You have the right to request and obtain a copy of your personal data and other supplementary information from us, free of charge;
• The right to rectification: You have the right to have inaccurate personal data that we hold about you corrected, or completed if it is incomplete;
• ‘The right to be forgotten’: You have the right to request for us to erase your personal data, although certain situations may not allow us to do this, including if we need to comply with a legal obligation to keep the specified data;
• The right to object and right to restriction of processing: You have the right to request the restriction or suppression of your personal data and its processing by us;
• The right to data portability: You have the right to obtain your personal data from us in an accessible and transferrable format, and reuse it for your own purposes across different services; and
• The right to make a complaint: You have the right to lodge a complaint about us in relation to our treatment of your information with the Information Commissioner’s Office (ICO), which is the UK supervisory authority for data protection (www.ico.org.uk/concerns; 0303 123 1113). We would appreciate you giving us the opportunity to deal with your concerns first! 

11. Linking to External Websites and Third Party Content

12. Use of cookies

13. Changes to Partner Privacy Policy

14. Contact Us